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HMRC internal manual

Capital Gains Manual

Non-resident companies: tax adjustment and reliefs: double taxation agreements

You should always check whether there is a double taxation agreement between the UK and the country in which the company making the gain is resident. If there is no double taxation agreement any TCGA92/S13 charge is unaffected. Similarly if the agreement does not refer to capital gains or Capital Gains Tax the charge under TCGA92/S13 is unaffected. But, if the agreement provides that gains of the type realised by the non-resident company are only taxable in that company’s country of residence TCGA92/S13 cannot apply. For example, Article 15(4) of the Kenya/UK Double Taxation Agreement would prevent TCGA92/S13 applying to the disposal of stocks and shares by a company resident in Kenya. Agreements will often treat gains on the disposal of particular types of asset differently.